ESOS Phase 4: Is Your Business Ready for January 2026?

If your business has a turnover exceeding £44.1 million or more than 250 employees, immediate action is required for the Energy Savings Opportunity Scheme (ESOS) Phase 4 compliance deadline in January 2026.

The statutory Energy Savings Opportunity Scheme (ESOS) has now entered Phase 4. For over 10 years, ESOS has delivered significant energy savings to larger UK businesses and organisations. It is a UK regulation that has demonstrably worked and provided substantial benefits to Britain’s larger organisations.

What is ESOS Phase 4?

ESOS Phase 4 is the latest compliance period of the mandatory energy assessment scheme for large UK undertakings. It requires qualifying organisations to conduct comprehensive energy audits, identify cost-effective energy saving measures, and report their findings to the Environment Agency.

Who Must Comply with ESOS Phase 4?

Does your company, or do any of your clients, fall into scope of ESOS Phase 4? Your organisation qualifies if it meets any of the following criteria:

• Annual turnover exceeds £44.1 million
• Annual balance sheet exceeds £37.9 million
• More than 250 employees
• Part of a larger corporate group that meets any of these thresholds

Typically, the Finance Director takes responsibility for ESOS compliance, but do not assume this has been addressed. Ensure your FD or client’s FD is aware of the requirements and deadlines.

When is the ESOS Phase 4 Deadline?

The ESOS Phase 4 compliance deadline falls in 2027, but critical preparation must begin immediately. The most important requirement is collecting monthly energy consumption data for a 12-month period that must include 31 December 2026.

This means companies should implement management procedures to collect monthly electricity and gas consumption data for all UK buildings starting from January 2026. Immediate action is now required.

What Data Must Be Collected for ESOS Phase 4?

As with previous phases, ESOS Phase 4 requires organisations to collect:

• Building energy data: Monthly electricity and gas consumption for all UK-based buildings for 12 months including 31 December 2026
• Transport data: Business vehicle mileage or fuel consumption collected in a robust manner
• Site survey data: Energy audits can be conducted during 2026 to identify energy efficiency opportunities and cost savings

How Vital Direct Supports ESOS Phase 4 Compliance

Vital has delivered ESOS solutions to a wide range of UK-based companies and organisations since the regulations started in 2014. We focus on making the process as simple and straightforward as possible for our clients. Our energy efficiency audits are pragmatic and appropriate for the size of buildings involved.

Vital is also one of the UK’s leading consultancies for commercial Energy Performance Certificates (EPCs), the UK’s national measurement system for energy efficiency in buildings. Increasingly, our ESOS clients are also seeking to improve the EPC grades for their UK buildings whilst identifying ways to eliminate gas boilers and transition to clean, electric winter heating systems.

Next Steps for ESOS Phase 4 Preparation

For an initial, no-obligation consultation, please call us on 0345 111 7700. We are a director-led UK-based business focused on human-to-human delivered advice.

To provide an ESOS Phase 4 proposal, we require:

• A list of the company’s UK buildings with approximate sizes
• An indication of vehicle fleet size and usage patterns

Further information is available from the official ESOS guidance on gov.uk.